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Puglisi and Mc Donald discussed how intangible asset subsidiaries might be created in Delaware to manage and protect Sherwin-Williams's marks, increase their value, and maximize the investment of royalty income. In addition, Sherwin-Williams relinquished control over monies it previously retained but now paid to the subsidiaries as royalties. They were invested (and therefore placed at risk) by the subsidiaries, under their own investment guidelines and with third parties outside of Sherwin-Williams's control. They also discussed Puglisi's expertise and interest in assisting the companies if Sherwin-Williams decided to create the Delaware subsidiaries. These advantages were known and considered by Mc Donald and Sherwin-Williams in evaluating the trademark subsidiary plan. These changes resulted from the reorganization and have legal, practical, and economic effects on Sherwin-Williams regardless of its stock ownership position. Under the IRC, only “ordinary and necessary” business expenses are allowable deductions. Conway Ivy, a vice-president and then treasurer of Sherwin-Williams, served as the second board member.
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The original boards of directors of each subsidiary were comprised of the same three individuals. The company took various tax deductions and depreciation allowances premised on its ownership of the building. The Commissioner of Internal Revenue challenged the company's right to those deductions and allowances, asserting, inter alia, that the bank was the owner of the building and the sale and leaseback should be disregarded as a sham for taxing purposes.
John Ault, the controller of Sherwin-Williams, served as chairman of both boards.
The contested assessment was the result of the commissioner's disallowance of approximately million that Sherwin-Williams had deducted from its taxable income for royalty payments to two wholly owned subsidiaries, Sherwin-Williams Investment Management Company, Inc. Exactly what constitutes an “ordinary and necessary” business expense has been the subject of much discussion over the years.
De Angelo, Special Assistant Attorney General, for Commissioner of Revenue. The Sherwin-Williams Company (Sherwin-Williams) appealed from a decision of the Appellate Tax Board (board) upholding the denial by the Commissioner of Revenue (commissioner) of its request to abate ,445.40 in corporate excise taxes assessed for tax year 1991, and we transferred the case to this court on our own motion. The issue here is whether the royalty payments for the use of the marks were ordinary and necessary business expenses.